Risk Assessment in Non-Profit Sector (KG0014)
Action Plan: Kyrgyz Republic Action Plan 2018-2020
Action Plan Cycle: 2018
Lead Institution: State Financial Intelligence Service under the Government of the Kyrgyz Republic (SFIS)
Support Institution(s): Public Fund “Civic Participation”, Ms.Erkina Ubysheva Mr.Bakyt Satybekov, member of the Public Council of MOF
Policy AreasCapacity Building, Civic Space, Legislation & Regulation, Legislative, Public Participation
Involving civil society in the risks assessment of terrorist activities in non-profit sector
Commitment Start and End Date
September 1, 2018 – August 31, 2020
Lead implementing agency/actor State Financial Intelligence Service under the Government of the Kyrgyz Republic (SFIS)
What is the public problem that the commitment will address? There are more than 29,000 non-profit organizations (hereinafter - NGOs) registered in Kyrgyzstan. Their efforts complement activities of the state in provision of important public services.
However, measures taken by the state in the framework of international obligations to combat terrorism financing may have a negative impact on activities of the conscientious NGOs due to burdensome or restrictive measures for the entire NGO sector activities.
What is the commitment? Involving representatives of civil society in the process of development methodological approaches to assess the risks of financing terrorist activities in the NGO sector and raising awareness of NGOs in matters of countering the financing of terrorist activities.
How will the commitment contribute to solve the public problem? Introducing risk-based approach will allow identifying NGOs with high risk of financing terrorist activities and taking targeted measures not limiting activities of the entire NGO sector.
Why is this commitment relevant to OGP values? Citizen participation: Involving civil society in assessing risks of financing terrorist activities in the NGO sector and planning follow-up actions.
Additional information This commitment complies with the law of the Kyrgyz Republic “On Anti-Money Laundering and Combating the Financing of Terrorism”
Milestone Activity with a verifiable deliverable Budget Start Date End Date
Activity 1: Methodological approaches to assess the risks of financing terrorist activities (hereinafter - FT) in NPO sector have been introduced.
1.1. Create a working group consisting of specialists of the competent state bodies, NPO representatives and SFIS Public Council members for the development of a methodology for FT risks assessment in NPO sector. Within SFIS budget October 2018 December 2018
1.2. Develop methodology of FT risks assessment in NPO sector, including:
- analysis of existing guidance documents and materials (FATF Recommendations, Methodology for assessing technical compliance with FATF recommendations and system effectiveness, FATF Guidelines for FT risk assessment at the national level, OSCE Guidelines for conducting national FT risk assessment, etc.).
- analysis of international practice of FT risks assessment in NPO sector.
- development and discussion of the draft Regulation on FT risks assessment with interested parties. Development partners’ funds October 2018 December 2018
1.3. Endorse Regulations on FT risks assessment in NPO sector, procedure for discussing the assessment results, publishing results of this assessment. Development partners’ funds October 2018 December 2018
Activity 2: Conduct joint risks assessment of FT in NPO sector and joint action planning.
2.1. Create a working group consisting of the competent state bodies, NPO representatives and members of the SFIS Public Council to conduct FT risks assessment in NPO sector. Development partners’ funds December 2018 March 2019
2.2. Assess FT risks in NPO sector. Development partners’ funds January 2019 March 2019
2.3. Present FT risks assessment report and publish results. Development partners’ funds February 2019 March 2019
Activity 3: Increase NPO awareness on countering FT.
3.1. Develop an information and training program in 2 languages (Russian and Kyrgyz). Development partners’ funds April 2019 August 2019
3.2. Posting countering FT materials on the SFIS website.
Development partners’ funds April 2019 August 2019
3.3. To hold at least 7 informational events (round tables, seminars) on countering FT in NPO sector. Development partners’ funds April 2019 August 2019
Activity 4: Development preventive measures against FT risks.
37.1. Develop and endorse action plan to address and reduce the identified FT risks in NPO sector. Development partners’ funds May 2019 September 2019
Expected result 1 1.1. The working group has been created.
1.2. A methodology for assessing the FT risks in the NPO sector of the Kyrgyz Republic has been developed.
1.3. The Regulation on FT risks assessment in NPO sector, the procedures for discussing assessment results, and publishing results of this assessment with the involvement of NPO representatives have been approved.
Expected result 2 2.1. The working group has been created.
2.2. FT risks assessment in NPO sector has been conducted.
2.3. Report has been presented, FT risks assessment results have been posted on the SFIS website and published in media.
Expected result 3 3.1. Plan of the informational educational program, measures and sources of financing have been approved.
3.2. Public access to information on countering FT has been provided.
3.3. NPOs have access to FT risks data.
Expected result 4 4.1. Based on the results of a joint assessment with representatives of civil society, the plan of action was approved.
Name of responsible person from implementing agency Mr. Suvanbek Aidinovich Duishenov
Title, Department Senior Inspector of the Legal Department, SFIS
Email and Phone Duishenov.firstname.lastname@example.org ph: 32-55-29
Other Actors Involved – State actors involved
CSOs, private sector, multilaterals, working groups Public Fund “Civic Participation”, Ms.Erkina Ubysheva
Mr.Bakyt Satybekov, member of the Public Council of MOF
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